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Comments on Recycling Statute from small Municipality

As the City's coordinator for municipal solid waste services and a past executive with the (then) third largest solid waste company in North America (Laidlaw Waste Services), I have been asked to provide comments on the Legislative Recycling initiative by one of our City Council members.

I want to say at the outset that as a community we actively strive to recycle. We provide single stream recycling services to our residents after years of curbside separation services. Our city program typically obtains about 70% household particpation currently (based on weekly route lifts -- not monthly recycling efforts). We are constantly looking for opportunities to expand the types of recyclables we can collect COST EFFECTIVELY and for ways to reduce the City's overall volumes landfilled.

I have reviewed the responses preceding my own posted to this topic. Frankly, I find it troubling how many respondents providing titles associating themselves with DEP seem to feel that simply providing recycling containers will solve the recycling issue.

I applaud and basically agree with the comments made by Ms Murray in this forum: ease and economics are critical considerations to successful recycling. I also believe that many of the thoughtful and insightful comments offered by the Curbside Value Partnership, the Heart of Florida Solid Waste Working Group, and Mr. Singer of Taylor County Environmental Services should be carefully considered, though I cannot endorse all of the recommendations cited.

Comments:

While the intentions are certainly laudable, the legislation is contradictory, in conflict with previous statutes, and arbitrary in its goals.

Recycling is not, in all cases and in all forms, universally "good for the environment", rarely cost beneficial in the current market, and typically imposed where it does the least good (at the residential level). The Statute implicitly presumes the contrary.

I do not wish to suggest that recycling is bad or something that should not be done, but it is imperative to recognize that economics and behavior drive disposal decisions more than statute, which means that this Statute will necessarily create an additional, artificial economic burden on the economy to comply.

Waste stream reduction requires systemic efforts, redesign and behavioral changes at all stages of production, distribution, consumption and disposal. This statute ignores all but the final two stages. Recycling activities are most productive at industrial/commercial levels. However, State Statute 403.7046(3) removes any local government authority over the disposition of commercial recyclables, so the new Statute defacto addresses only residential and non-commercial (schools and churches) recycling.

Recycling is the last, and most expensive, defense of airspace in landfills, not 'defense of the environment'. There is nothing that inherently benefits the local environment by recycling: it usually requires more energy to collect, separate, and reprocess; it always requires more transportation; cleaning and decontamination of materials requires water and/or chemical treatments; and, in some cases, the relatively small scale of product manufacturing of "green products" from recovered materials is significantly more inefficient than large scale manufacture from virgin materials and thereby using more energy, and producing more waste proportionately. It may be globally better for the environment to recycle aluminum to avoid excessive bauxite strip mining and reduce energy needs for ingot production in some other location, but locally the impact will be detrimental to the environment by some degree. Much better to reduce or reuse -- but economics and behaviors need to align with and reinforce achieving such goals.

Let us be clear: recycling is not, and cannot be considered, simply the collection of defined materials. That is only a small portion of the equation that must be evaluated. Such materials will only end up in a landfill somewhere else (another county, state or another country) unless those materials are properly separated, decontaminated, and there is an active, stable market for those materials.

Please refer to the uploaded PDF primer on recycling systems and economics produced for the City of New York. It may be a useful resource in helping to fully verse participants in this discussion on the variety of issues and considerations that impact this topic.

Successful recycling depends first, and foremost, on having a strong, stable market for the collected recyclables -- and for that material to be cost effective in its reuse. Currently, such stability exist solely in the metals markets. Impurities and contaminants in most residentially collected recyclable materials render them unfit for remanufacture, so they are not recycled in the true sense of the word but become feedstock for alternative products.

A growing, and critically important aspect of waste management is End Of Life Electronics (EOLE), which unfortunately is also one of the most difficult challenges to overcome. This is also one of the fastest growing segments of our waste stream today.

Both precious metals and toxic heavy metals are used in small quantities in today's technology. The current expedient "recovery" methodology is to ship them to "recycling" centers in the third world countries where they are typically burned in small open air incinerators to recover a portion of the metals. Clearly, this methodology is not environmentally friendly, nor should it be acceptable, but it is currently economic. The difficulty of creating a clearing house for EOLE components and operating facilities for deconstruction of EOLE in scales that are economic requires a complex combination of skills, knowledge, and financial resources. This is a problem worthy of tackling and one that would make Florida world-class were it to succeed.

Several European countries have pursued a broad systemic approach to waste management, targeting the source of waste in manufacturing with a novel approach: any packaging, product or disposable component shipped out by a manufacturer, wholesaler or retailer must be accepted back without charge. This provides direct economic incentive for each business to invest in design and packaging that is minimal or non-existent can be reused, retasked, or efficiently and economically recycled. It encourages non-disposable product lines and distribution and display methods that are innovative and not wasteful. And, surprisingly, it works. Unfortunately, such a solution requires federal legislation since Florida is not self sufficient in manufactured goods.

The simplest, most expedient (as well as most politically and financially painful) means of waste reduction is economic. A statute requiring a state tax on the disposition or export of all waste on the order of, say, $500 per ton will rapidly and massively change the economics of waste, and encourage aggressive recycling and composting. There are two primary problems with this approach (aside from the fact that all elected officials endorsing such tax will lose their seats): 1) municipal landfills that generate revenue for their general fund will see a precipitous drop in revenue as a result, and 2) the State will experience an initial windfall of revenue that will rapidly diminish faster than the costs of the programs such revenues are earmarked to fund. But, at such prices the 'invisible hand' of the economy will find multiple ways to reduce, reuse, repurpose, rebuild, recycle, mulch, and compost waste. At $500+ per ton, it is very economic to recover almost the entire waste stream -- at $18 to $35 per ton virtually nothing but metals are economic to recover. This solution might work, but would also bankrupt the tourist industry that Florida relies so heavily on for income.

The difficulty with the Statute is that it does not demonstrate the specificity or depth of thought to succeed without inequities and becoming another unfunded mandate burden on local municipalities. It appears to effectively penalize any areas that are aggressively managing waste streams currently. Investment / grant criteria to encourage success is nebulous. Finally, it is unclear who is to be ultimately responsible for changes in waste stream management as well as what incentive exist for success, and what penalties for failure. It is focused solely on collection rather than on fostering demand for the recycling feedstocks (i.e. grants/loans for developing businesses who use these feedstocks). Hence, the end result cannot help but be storage yards filled with mountains of recyclable materials neatly separated but without a use -- or being shipped out of state to be dumped in some inexpensive landfill in Georgia, Kentucky or Tennessee. Certainly, such is not the intent.

Sadly, it is a goal and program without sufficient scope or specificity of vision or definition and as a result looks more like campaign sound-bite rhetoric than a meaningful strategic goal.

As Kermit so eloquently put it: it's not that easy being green. We can, and we must do better... far better.